JUDGMENT

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J. (Oral)

CM No.53514/2023 [Application filed on behalf of the appellant seeking condonation of delay of 288 days in re-filing the appeal]

1. This is an application moved on behalf of the appellant/revenue seeking condonation of delay in re-filing the appeal.

1.1. According to the appellant/revenue, there is a delay of 288 days in re- filing the appeal.

2. For the reasons given in the application, the prayer seeking condonation of delay in re-filing the appeal is allowed.

3. The application is disposed of, in the aforesaid terms.

ITA 579/2023

4. This appeal concerns Assessment Year (AY) 2012-13.

5. Via the instant appeal, the appellant/revenue seeks to assail the order dated 30.03.2021 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"].

6. The appellant/revenue has proposed the following questions of law for our consideration:

"A. Whether on facts and circumstances of the case and in law, Hon'ble ITAT has erred in deleting the disallowance of Rs 20,84,878/- u/s 14A r/w Rule 8D of the Income Tax Act 1961?

B. Whether on facts and circumstances of the case and in law, Hon'ble ITAT has erred in deleting dis